A SNAPSHOT OF GERMANY'S EIA APPROACH IN LIGHT OF THE UNITED STATES ARCHETYPE

November 2010 marked the 25th anniversary of the EU Environmental Impact Assessment Directive and the 20th anniversary of its implementation in Germany via the Environmental Impact Assessment Act (EIAA) in 1990. Reflecting back to the original role model for these pieces of legisiation, the 1969 US National Environmental Policy Act (NEPA) can bring some interesting differences to light. Four decades of experience from the more mature US EIA system may hold some important lessons for Germany's younger EIAA. While an outright comparison is impossible at this present time, this article aims to contribute a comparative perspective to show the current status of the original US model, NEPA, and the differences in development and practice to Germany's younger EIAA.